ABSTRACT
The arrival in the UK of the Proceeds of Crime Act 2002 (‘POCA’), and specifically sections 327 to 329, as amended by the Serious Organised Crime and Police Act 2005 (‘SOCPA’), was widely regarded as contributing a significant weapon to the armoury deployed in the fight against crime. This Act provided a far wider range of powers, beyond AML provisions, covering not only criminal3 but also civil recovery.4 For a government focused on proving the adage that ‘crime does not pay’, it provided the recovery agency with ‘powers that were so extensive it could even seize assets from people who had not been convicted of any crime’.5
